SanctionsLookupOFAC Enforcement Actions in 2011
OFAC published 21 civil penalties and settlements in 2011, totaling $91.7 million, 54% less than the 2010 total of $200.7 million (27 actions). The largest 2011 OFAC penalty was $88.3 million against JPMorgan Chase Bank, N.A. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$91.7Mvs 2010: $201M
- Total actions21vs 2010: 27
- Largest penalty$88.3Mvs 2010: $176M
2011 OFAC Penalties
2011 OFAC Enforcement by the Numbers
OFAC resolved 19 of its 21 enforcement actions in 2011 through settlements and issued 2 penalty notices. The median penalty was $37,080. Enforcement was concentrated in the second half of the year, with 9 actions in the first half and 12 in the second, including 7 in the fourth quarter.
Iran-related sanctions were cited in 16 of the 21 actions, Sudan in 6, and Cuba in 5. Insurance accounted for 5 actions, and banking and trading for 4 each. 20 actions targeted companies and 1 targeted individuals.
OFAC found that 5 of the 21 cases involved voluntary self-disclosure. All 21 parties were based in the United States.
By total penalties, 2011 ranks 3rd of the 9 years in this database, and 9th by number of actions. For the 17 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $2.5 million; those parties ultimately paid $1.5 million, an aggregate 39% reduction.